ML14175B003
| ML14175B003 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/30/1978 |
| From: | Gibson A, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B001 | List: |
| References | |
| 50-261-78-23, NUDOCS 7812070312 | |
| Download: ML14175B003 (8) | |
See also: IR 05000261/1978023
Text
I
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION It
o0
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30303
Report No.:
50-261/78-23
Docket No.:
50-261
License No.:
Licensee:
Carolina Power and Light Company
336 Fayetteville Street
Raleigh, North Carolina 27602
Facility Name: H. B. Robinson 2
Inspection at: Hartsville, South Carolina
Inspection Conducted: October 2-6, 1978
Inspection:
G. R. Jenkins
Reviewed by:
________--__
_-__-____
jXA~F. Gibson, Chief
Date
Radiation Support Section
Fuel Facility and Materials Safety Branch
Inspection Sumary
,nspection
on October
2-6,'
1978
(Report
No.
50-261/78-23)
Areas
Inspected:
Routine, unannounced inspection of spent fuel shipments,
solid radwaste,
personnel overexposure,
follow-up on previous inspection
items, and IE Circular and Bulletins.
The inspection involved about 32
inspector-hours on-site by one NRC inspector.
Results:
Of four areas inspected, no apparent items of noncomplianlce were
identified in two areas; two items of noncompliance were identified in two
areas (Infraction-Exposure greater than 5(N-18) (78-23-01), InfractionWaste
drums not surveyed for contamination prior to shipment (78-23-02)).
ThP
RII. Report No.: 50-261/78-23
-2
DETAILS I
Prepared by:
,
/,7
Je
ns, Radiation Specialist
ate
Radiati
Support Section
Fuel Facility and Materials Safety Branch
Dates of Inspection: October 2-6, 1978
Reviewed by:___
__ __ __ __ __ _
7$'
' AVF. Gibson, Chief
Date
Radiation Support Section
Fuel Facility and Materials Safety Branch
1. Individuals Contacted
- R. B. Starkey, Jr., Plant Manager
- D. S. Crocker, E&RC Supervisor
J. A. Eaddy, RC&T Foreman
G. B. Moore, RC&T Foreman
F. Lowery, Training Coordinator
J. Sawyer, Engineering Technician
6 RC&T Technicians
- Denotes those present at Exit Interview.
2.
Licensee Action on Previous Inspection Findings
(Closed) Deficiency (78-05-01).
Containers not properly labeled.
An
inspector reviewed corrective actions as described in CP&L's supplemental
response of July 18, 1978, and determined that actions taken appeared
to be effective.
This item is closed (Details I, paragraph 4).
(Closed) Infraction (78-05-03).
Respirators not surveyed for fixed
contamination. An inspector reviewed recent respirator survey records
and found them to be acceptable.
Also, during the inspection, respirator
storage cabinet shelves were repositioned to preclude the stacking of
respirators.
This item is closed.
(Closed)
Open Item (78-05-04).
Whole body counting program.
An
inspector reviewed Health Physics Procedure HP-32, "Personnel Whole
Body Counting",
issued July 1, 1978,
and had no further questions on
this item.
(Closed)
Infraction
(78-13-01).
Radiation area not conspicuously
posted. An inspector reviewed corrective actions, as stated in CP&L's
letter of July 26, 1978, and had no further questions.
All radiation
areas observed during plant tours were conspicuously posted.
RII. Report No.: 50-261/78-23
-3
(Closed)
Deficiency
(78-13-02).
Current copy of
10
CTR
20 not
available. An inspector reviewed corrective actions, as stated in
CP&L's letter of July 26, 1978. The inspector verified that current
copies of 10 CFR 20 are now available.
This item is closed.
(Closed) Open Item (78-13-03). Control of TLD badges. The licensee
has decided to have TLD badges distributed by security guards at the
Unit 2 control point, to begin about mid-October when badge racks are
installed.
The inspector had no further questions.
(Closed)
Open Item (78-13-04).
Missing radiation monitor qualifi
cation card.
An inspector verified that the individual in question
had been re-qualified effective July 2, 1978.
(Closed)
Open Item (78-13-05).
Calibration of containment and plant
vent gas monitors. An inspector verified that RMS-12 and RMS-14 were
calibrated on August 16, 1978.
(Open)
Open Item (78-21-02.).
Radiological controls associated with
fuel cask loading.
An inspector discussed this item with RC&T personnel,
who agreed to certain improvements.
This item remains open pending
review of the improved controls (Details I, paragraph 5).
3.
Unresolved Items
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items,
items of
noncompliance, or deviations. An unresolved item disclosed during the
inspection is discussed in paragraph 6.
4.
Labeling of Radioactive Material Containers (78-05-01)
During tours of the auxiliary building, an inspector observed that
containers of radioactive material appeared to be properly labeled.
The inspector reviewed instruction HPI-2,
"Handling of Radioactive
Trash" and had no questions.
In discussing the scope of 10 CFR 20.
203(f), the E&RC Supervisor said that drums of compacted waste had not
been labeled as radioactive material while stored in a locked, posted
area of the drumming room waiting shipment. The inspector stated that
these should be labeled,
and the E&RC Supervisor stated that this
would be done.
The inspector had no further questions.
RII. Report No.: 50-261/78-23
-4
5.
Radiological Controls Associated with Fuel Cask Loading
(78-21-02)
An inspector discussed some specific areas of concern, previously
identified in Region II Report No. 50-261/78-21, with RC&T personnel.
The E&RC Supervisor stated that improved health physics coverage would
be applied to activities in the fuel handling building, and the following
specific actions would be taken:
a.
A frisking station will be established for personnel involved in
fuel cask loading and handling;
b.
The hooki*cables of the cask crane will be surveyed for contam
ination prior to storage after each cask loading evolution;
c.
More specific information linking protective clothing require
ments to the type work to be performed will be included on
radiation work permits for fuel handling jobs.
The inspector stated that this item will remain open pending review of
these controls.
6.
Spent Fuel Shipments
a.
An inspector reviewed shipping documentation associated with
transfers of spent fuel from H. B. Robinson to Brunswick made on
September 12,
1978,
September 20,
1978,
and October 6,
1978.
Each shipment includes seven fuel assemblies in Model IF-300 cask
transported by railcar. These records indicated that about 40 to
50 points on the cask were checked for surface contamination each
shipment, and, prior to shipmeft, all smears on the cask indicated
less than 20,000 dpm per 100 cm
b.
In reviewing the radioactive material shipment record for the
October 6,
1978 shipment prior to its departure, the inspector
stated that the locations of the radiation measurements,
as
recorded,
were not clear.
The E&RC Supervisor concurred,
and
stated that the cask and enclosure would be re-surveyed prior to
releasing the shipment.
The inspector also determined that no
record was maintained of the full radiation survey of the cask
and enclosure for this or past shipments.
The only recorded
radiation data was on the radioactive material shipment records.
The E&RC Supervisor stated that detailed radiation survey records
for spent fuel shipments would be maintained for subsequent
0
shipments.
RII. Report No.: 50-261/78-23
-5
c. During a discussion of spent fuel shipment surveys,
the E&RC
Supervisor disclosed to the inspector an intra-Company memoran
dum,
dated January 25,
1978,
which established a
CP&L policy
that,
for the purpose
of evaluating surface
contamination
associated
with
the
Model
IF-300
shipping container,
the
retractable aluminum enclosure is considered the outer surface of
the package. Also, based upon that memorandum, the licensee has
determined the transport index of shipments to be equivalent to
the dose rate at 3 feet from the surface of the enclosure.
The
memorandum references the definitions of "package" and "packaging"
from
10 CFR
71.3,
discusses the contents of Certificate of
Compliance No. 9001, notes that 10 CFR 20.205(b)(2) addresses the
external surfaces of the "package",
and concludes that "...the
entire unit constitutes the PACKAGE, and the contaminations apply
to the outer surfaces of the package, which is the ENCLOSURE".
The inspector questioned CP&L's interpretation that the aluminum
enclosure, rather than the spent fuel cask,
is the package for
purposes of determining contamination levels and the transport
index of a shipment.
The inspector identified this as an
unresolved item pending resolution of the interpretation of the
meaning of "package" as stated in
49 CFR
173.389(i) (referenced by 10 CFR 71.5), and USNRC Certificate of
Compliance No.
9001 (78-23-03).
The inspector also took note of
the statement in the CP&L memorandum that, in a few instances,
the spent fuel cask has arrived at Brunswick Plant with contami
nation levels on the cask in excess of the limits of 10 CFR 20,
even though considerable decontamination took place at the H. B.
Robinson Plant and was shipped with levels less than the limits.
7.
Radiation Exposure Exceeding 5(N-18)
a.
On July 25,
1978,
CP&L Harris Energy and Environmental Center
personnel discovered that a contract janitor had received exposure
of 5.490 rem, which exceeded the permissible accumulated dose of
5 rem for his age of 19 years at that time.
This was verbally
reported to Region II and a letter report, dated August 22, 1978,
was sent to the Director, OIE, in accordance with the requirements
of 10 CFR 20.405. Also, a report was provided to the individual
on August 18, 1978, in accordance with 10 CFR 19.13.
b.
An inspector discussed the report and the sequence of events with
the E&RC Supervisor.
The overexposure apparently resulted from
erroneous information supplied in computer reports generated at
the Harris Center.
Through a series of data entry errors, the
individual's lifetime dose was equated to his calendar year dose
on the computer record issued for March 1978, thereby deleting
RII. Report No.: 50-261/78-23
-6
his pre-1978 accumulated dose of 1.584 rem. Thereafter, the dose
allowable,
based on the computer report, was in error by that
quantity until the discrepancy was identified during a review of
the computer reports on July 25.
As indicated in the CP&L report,
the underlying cause of this incident is
the failure of the
review process at the Harris Center to perform adequately.
c.
The inspector cited the reported exposure as noncompliance with
10 CFR 20.101(b), and stated that no response to this item in the
Notice of Violation would be required since both interim and
long-range corrective actions were outlined in CP&L's report
(78-23-01). The inspector verified by review of records and
discussion with licensee representatives that an interim monthly
review of the computer generated record is
conducted at the
plant, including calculations of accumulated exposure for indi
viduals with a permissible-accumulated dose of less than 10 rem.
The inspector stated that this item would remain open pending
review of the expanded audit program to be implemented at the
Harris Center in the first quarter of 1979.
8.
Solid Radioactive Waste Shipments
a.
An inspector discussed IE Circular 78-03, "Packaging Greater Than
Type A Quantities of Low Specific Activity Radioactive Material
for Transport",
with licensee representatives.
The inspector
reviewed procedure HP-20,
"Shipment of Radioactive Materials",
and noted that the procedure specifically cautions against
shipping LSA
in
a non-specification container
if
the total
quantity is Type B. The inspector also reviewed selected
radioactive material
shipment records
covering the period
January-June 1978, and had no questions.
b.
In reviewing the "Effluent and Waste Disposal Semi-Annual Report,
January-June 1978", the inspector noted an apparent error in the
total activity of solid waste shipments (p. 14).
Licensee repre
sentatives stated that the error had been identified by CP&L.
personnel and that a supplement to the report was being prepared.
The inspector stated that the supplemental report would be reviewed
when received (78-23-04).
c.
An inspector observed packaged drums of radioactive waste being
removed from the auxiliary building for storage prior to shipment.
The drums were lowered by crane from the second level of the
building to the outside paved area.
Each drum was placed in a
yellow polyethylene bag for storage and shipment.
When questioned,
RII. Report No.: 50-261/78-23
-7
RC&T personnel said that the bags were used to assure no
significant removable surface contamination on the exterior of
the package, which is a general requirement of 49 CFR 173.393(h),
and that no measurements of surface contamination were made. The
inspector questioned if the integrity of the plastic bags was
maintained throughout the handling, loading, and shipping of the
drums.
The E&RC Supervisor acknowledged that tears in the bags
did occur. He stated that absorbent paper was placed under the
drums on the exclusive use truck, but agreed that the plastic
bags could not be considered "strong, tight containers".
The
inspector cited failure to survey the drums for removable
contamination prior to shipment as noncompliance with 10 CFR
71.5(b),
which requires that the licensee conform to the
Department of Transportation requirements
(78-23-02);
49 CFR
173.393(n)(9) requires that, prior to shipment of the package,
the shipper shall ensure that contamination levels are within the
allowable limits. The E&RC Supervisor stated that, thereafter,
the drums would be surveyed for contamination prior to shipment.
O0 9.
Fire in Ventilation System
On October 4,
1978,
a fire occurred inside a ventilation duct in the
former laundry area of the auxiliary building.
That area was being
remodeled to provide shower and change facilities for female workers.
In the process of cutting a channel iron sleeve around the duct, a
worker cut through the duct with a torch, igniting lint which had
accumulated
from long-term operation of a clothes dryer.
The
resulting fire was mostly smouldering material with a lot of smoke and
very little flame.
The inspector observed the activities of plant
personnel while the fire was contained and extinguished, noting
particularly that respiratory protection was worn by personnel in the
immediate area and that air sampling was done.
Thirteen air samples
were taken in areas of the auxiliary buildin where smoke was observed.
The maximum gross concentration was 1x1O
uCi/cc; no activity was
detected on isotopic analysis of these samples.
Two iodine air samples
were collected, but no activity was detected.
During subsequent
discussion, a RC&T Foreman said that the workers had discussed the
cutting job with him prior to starting.
He said that no radiation
work prmit was issued because there was no intent to cut into the
duct. The inspector had no further questions regarding the radio
logical aspects of the response to the fire.
10. IE Bulletin 78-07 - Protection Afforded by Airline Respirators
and Supplied-Air Hoods
An inspector discussed CP&L's letter of August 14, 1978, in response
to the subject bulletin.
Neither supplied air hoods nor respirators
in the demand mode are used at H. B. Robinson.
RII. Report No.: 50-261/78-23
-8
11.
IE Bulletin 78-08 - Radiation Levels From Fuel Element Transfer
Tube
An inspector discussed CP&L's letter of August 14, 1978,
in response
to this bulletin, with the E&RC Supervisor.
The response stated, in
part, that although no portion of the transfer tube is accessible in
the unshielded condition, a proposed plant modification will result in
fencing and locked gates being placed around the high radiation areas
adjacent to the shielded tube to further control personnel access
during fuel transfer.
The inspector reviewed the record of a radiation
survey conducted November 20, 1975, during fuel transfer which showed
a maximum radiation level of 350 rem per hour in the space underneath
the refueling canal.
The inspector reviewed minutes of the PNSC
meeting of April 14, 1978, (erroneously stated as April 4, 1978 in the
CP&L response) in which the need for the plant modification was discussed.
Plant management stated that the modification will be accomplished
during the next refueling outage prior to transferring any fuel. The
inspector stated that this item would be further reviewed at that time
(78-23-05).
12. Effluent Radiation Monitors
a.
An inspector discussed with licensee representatives an event
which occurred at another facility involving the condenser air
ejector monitor. After a significant leak in a stream generator
tube, the monitor spiked momentarily but then returned downscale
due to saturation of the GM detector due to high radiation.
GM
detectors are used as gas monitor detectors at H. B. Robinson.
Section 7.2 of System Description 7, "Radiation Monitoring System",
states that the monitors are of a non-saturating design and will
peg full scale if exposed to levels up to 100 times full-scale
indication.
b.
The inspector also discussed an event at another facility where a
continuous iodine stack monitor gave erroneous readings due to
detection of noble gases.
The E&RC Supervisor said that the
stack effluent monitor includes an iodine monitoring channel, but
that plant personnel recognize that the iodine monitor responds
to noble gases during any high gaseous activity release.
13.
Exit Interview
The
inspector
met with management
representatives
(denoted
in
paragraph 1) on October 6, 1978, and summarized the scope and findings
of the inspection.
Items discussed included two items of noncompliance
and one unresolved item discussed in this report.